October 15, 2015 - The FAA has issued new
guidance to agency inspectors that should
provide relief from pilot-checking challenges
faced by Part 135 operators due to a shortage of
check airmen. The new guidance is found in FAA
policy notice: “Flight Standards Inspector
Resource Program (FSIRP) Policy Updates and Job
Qualification Matrix.”

NBAA worked for many months to increase the
FAA’s awareness of this issue, lobbying for
additional resources and recommending policy
changes to meet Part 135 operators’ testing and
checking needs.

“In the past, a major issue when requesting
national resources was that local [Flight
Standards District Offices] FSDO managers would
not let inspectors in the national resource
program travel to another region to do checks
since the inspector was part of that local
FSDO’s budget,” said W. Ashley Smith Jr., CAM,
and president of Jet Logistics Inc. “This notice
addresses those budget concerns and also
requires FSDOs with a requested national
resource inspector to respond to the requesting
FSDO within five business days. Overall, this
notice is a positive step.”

The problem arose in recent years when changes
to FAA policies and processes significantly
reduced the number of in-company FAA check
airman authorized for specific Part 135
certificate holders, resulting in Part 135
operators relying on FAA “national resources” to
complete required Part 135 checking events.

The FSIRP maintains a cadre of national resource
inspectors (NRI) – often referred to within the
industry as “national resources” – throughout
the country, who are appropriately trained and
qualified on specific aircraft types. These
inspectors are responsible for completing
testing and checking functions in the aircraft
for which they are type rated.

However, long response times due to insufficient numbers
of qualified NRIs, plus local FSDOs’ funding concerns
and scheduling issues, often led to substantial delays
in testing and checking. These delays caused operational
and financial concerns for Part 135 operators. This new
policy notice is significant in that it clarifies the
process for inspectors to respond to testing and
checking requests, addresses local FAA offices’ funding
worries and establishes national resource testing and
checking as a priority for qualified inspectors.
However, the new policy requires operators to provide at
least a 30-day notice when requesting a test or check
through an NRI.

This could present a challenge to operators when
requesting initial testing or checking for a new-hire
pilot, for example, as the lead time for a new pilot is
often far less than 30 days. If an operator does not
receive options for the requested test or check in a
timely manner, the operator should consider discussing
it with their principal operations inspector or
elevating the request, if necessary. NBAA hopes that
individual inspectors will recognize this challenge with
new-hire pilots and work with operators to complete
initial checks as quickly as possible.
“This policy notice is the result of months of
collaboration between the FAA and industry,” said Brian
Koester, NBAA project manager of operations. “We
appreciate the attention the FAA has given this matter
and believe this recent policy notice will alleviate
many testing and checking concerns of the Part 135
industry.”